IP Law Daily, PATENT—Fed. Cir.: Summary judgment of noninfringement in curved treadmill patent dispute vacated due to narrow claim construction, (Jul 27, 2026)

By Carolin Dennis, B.Sc., LL.B., LL.M.

District court erred in its construction of “substantially prevent” and should have construed the claim term in line with its plain and ordinary meaning.

In a non-precedential disposition, the U.S. Court of Appeals for the Federal Circuit vacated and remanded the district court’s decision granting summary judgment of noninfringement in favor of LifeCORE Fitness, LLC. The Federal Circuit found that the district court relied on an overly restrictive claim construction and agreed with the patent holder that the district court’s construction was erroneous (Woodway USA, Inc. v. Lifecore Fitness, Inc., No. 25-1431 (Fed. Cir. Jul. 21, 2026)).

Woodway USA, Inc. (Woodway) owned U.S. Patent Nos. 9,039,580 (’580 patent); 10,561,884 (’884 patent); and 10,799,745 (’745 patent) (collectively, the Asserted Patents), which share substantially overlapping specifications and a common parent application. These patents are generally directed to manual treadmills with a curved or contoured running surface. In April 2022, Woodway filed suit against LifeCORE Fitness, LLC, dba Assault Fitness (LifeCORE), alleging that certain manual treadmills offered by LifeCORE infringed the Asserted Patents. During claim construction, Woodway argued that, regarding the “substantially prevent” limitation, “substantially” should be given its plain and ordinary meaning of “entirely/largely/mostly/generally though not necessarily entirely,” and “prevent” need not be construed. Meanwhile, LifeCORE, argued that “substantially prevent” ought to be construed as “prevent any movement after allowing no or minimal movement.” However, the district court construed the limitation to mean, “restricts rotation to allow for only one rotational directionof movement.” Further, as LifeCore introduced evidence showing that the accused products’ running belts can rotate fully in two directions under normal conditions, the district court granted summary judgment of noninfringement for LifeCore in January 2025. Woodway appealed arguing that: (1) the district court’s construction of “substantially prevent” as requiring complete prevention of rotation in the dispreferred direction, and (2) the district court’s subsequent grant of summary judgment were erroneous.

Claim construction. Woodway argued that the district court erred in construing the “substantially prevent” limitation by deviating from its plain and ordinary meaning and finding prosecution disclaimer of treadmill belt movement in a second direction. The district court concluded that the Asserted Patents “do not elaborate on the degree to which the safety device impedes rotation of the belt in the second direction.” However, the Federal Circuit found that the claim language broadly specified that rotation in the second, dispreferred direction is “substantially” prevented. Further, the Federal Circuit found this understanding consistent with Woodway’s originally proposed plain and ordinary meaning of “substantially prevent”—that is, “entirely/largely/ mostly/generally though not necessarily entirely” prevent. Additionally, no phrasing in the Asserted Patents’ specifications was inconsistent with the plain and ordinary meaning of “substantially prevent” suggested by Woodway. Under these circumstances, the Federal Circuit declined to find “words or expressions of manifest exclusion or restriction” in the Asserted Patents’ specifications that limit the plain and ordinary meaning of the “substantially prevent” limitation.

The district court had also rejected Woodway’s proposed construction because it found that Woodway had clearly and unmistakably surrendered an invention allowing bidirectional movement of the treadmill belt during prosecution of the ’884 patent when it distinguished two prior art references, U.S. Patent No. 5,492,517 (Bostic) and U.S. Patent Application Publication No. 2005/0009668 (Savettiere). However, regarding Bostic, the Federal Circuit found that Woodway’s argument that Bostic’s belt is “free to move” in both directions says nothing about the amount of limitation the claimed treadmill places on the dispreferred direction of movement—it simply distinguishes a device that impedes movement in one direction from a device that does not. Therefore, the Federal Circuit found no prosecution history disclaimer resulting from Woodway’s arguments on Bostic. Similarly, for Savettiere the Federal Circuit found that Woodway’s prosecution statements addressed a different structural distinction and did not specify whether prevention of movement in the dispreferred direction needed to be absolute. Thus, the Federal Circuit declined to find that Woodway clearly and unmistakably disclaimed a treadmill capable of bidirectional belt movement because it noted “multiple reasonable interpretations” of the prosecution history. Accordingly, the Federal Circuit concluded that the district court erred in its construction of “substantially prevent” that relied on prosecution disclaimer to narrow the scope of the claim limitation.

Summary judgment. Woodway first argued that, under the plain and ordinary meaning of “substantially prevent,” there is no dispute that LifeCORE’s accused products infringe. Further, Woodway argued that summary judgment must be vacated because the district court’s infringement analysis either relied on a flawed claim construction or resolved factual disputes regarding the amount of force needed to operate the accused products in the dispreferred forward direction. However, the Federal Circuit found that the grant of summary judgment of noninfringement was derived from an erroneous claim construction. Accordingly, the Federal Circuit vacated the district court’s grant of summary judgment of noninfringement and remanded for further proceedings.

The Case is No. 25-1431.

Judge: Hughes, T.

Attorneys: Kadie M. Jelenchick (Foley & Lardner LLP) for Woodway USA, Inc. John S. Leroy (Brooks Kushman PC) for Lifecore Fitness, Inc.

Companies: Woodway USA, Inc.; Lifecore Fitness, Inc.

Cases: Patent FedCirNews